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* * * I feel it will be fair to stipulate that
before consideration be given to future meetings, the
IRS will be required to have the citations of law
and/or authority and support data we requested
delivered into our hands at least two weeks prior to
the time any meeting is scheduled. * * *
21 days will be considered a reasonable time in
which to furnish the citations of law and/or authority
and support data. * * *
On January 2, 1996, petitioners requested from Ms. Teichrow
a complete copy of respondent's administrative file. Ms.
Teichrow responded by letter dated January 2, 1996, as follows:
In response to Mr. Hasbrouck’s request for a copy of
the entire file, I am enclosing a complete copy of the
examiner’s report including workpapers showing the
adjustments made for 1990, 1992, 1993 and 1994. I have
not copied the entire file as much of the remainder is
correspondence.
I acknowledge receipt of your letter dated December 20,
1995. It is my understanding from this communication
that you have declined to meet with me on January 18,
1996.
I will not be responding to your request for “citations
of law and/or authority and support data” within 21
days. As previously advised, my work is managed on a
first-in, first-out basis. As such, I have not had an
opportunity to make an in-depth review of your case.
In a letter to Ms. Teichrow dated January 3, 1996,
petitioners acknowledged receipt of the copy of the examiner’s
report and stated:
The IRS steadfastly refuses to furnish any proof that
the deficiency it claims is based on law or fact, in
spite of telling us: “Previous court ruling[s] have
determined ...” “What” previous court rulings? Court
rulings have designations so we can look them up.
“What” are those designations?
I do decline to meet with you until such time as you
comply with the request made by this taxpayer on
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